App Data Protection and Privacy Policy

Effective Date: May 31st, 2018

Last modified: February 10, 2021

What is this policy?

Hiya, Inc. (“Hiya” or “We”) values your privacy and we have prepared this Privacy Policy (“Policy”) to help you understand how we collect, use, and disclose information that we obtain about users of our mobile applications, services, and corresponding Web sites (collectively, our “Apps”), and how we use and disclose that information. We explain who we are, why, on what legal basis, and how we process personal data and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

By accepting our Terms of Service and this Policy and/or using our Apps, you agree that your personal information will be handled as described in this Policy. Your use of our Apps, which includes any services available through our Apps, is subject to this Policy and our Terms of Service, not including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Policy.

Please note that our Apps may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites and We are not responsible for the information practices of such websites.

Who are we?

We are Hiya, Inc. Our contact and other details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).

Our details – options to contact us:

- US Office: 110 Union St., Suite 500, Seattle, WA 98101 USA

- Email: support@hiya.com

- Follow this link to contact Hiya Customer Service

- Data Protection Officer: e-mail: dpo@hiya.com

- UK Office: Churchill House, Churchill Way, Cardiff CF10 2HH, Contact: Alex Algard

- EU/ Hungary office: 1066 Budapest, Mozsár utca 16. 5th floor, Contact: Daniel Lehoczky

What does the Hiya App do?

The Hiya App enables users to: (a) have incoming calls identified by Hiya as a potentially “unknown identity/reputation” that are either missed or rejected by the user, to be automatically forwarded to a voice messaging system hosted by Hiya that would appear on the App for retrieval by the user, in the event the caller leaves a voice message. The App is offered by Hiya on a purely opt-in basis and therefore user would have to affirmatively elect to use it. Similarly, users can disable the App at any time, even after opting in to use it.

Whose personal data do we process?

We may process personal data relating to you if:

Social Network User IDs

In case you are one of our users and access some of our Apps using your social networking account credentials, we may obtain information from Facebook, LinkedIn, Twitter and Google+: If you log into our Apps using these social networking accounts, you must enter your social networking account email address and password. We will ask that you grant us permission to your social networking account user IDs which we will use to authenticate you to use our service. Since your social network account user ID is unique, we do not have to create a new ID ourselves. Instead, we will use your social network account user ID to identify you as a user in our Apps. If you allow us to have access to your social network account user ID, then our Apps may be visible on your social network page that lists your “applications.”

We store your social network account user ID that we receive from your social network account along with other information that we collect from you or receive about you. The third-party social networking site will know that you are a user of our Apps and certain usage information. For information about how they may use and disclose this information, including any information you make public, please consult their respective privacy policies. We have no control over how any third-party site uses or discloses the personal information it collects about you. Any access to and use of a social network is not governed by this Policy, but instead of governed by the policies of those social networks. We are not responsible for the information practices of such social network websites.

Children Under 16

Our Apps are not designed for children under 16 and Hiya does not make its’ Apps available to Children under 16. If you are under the age of 16, you may not download the Apps or use the Apps, you may not use any feature that requires registration, and you may not provide us with any of your personal details. If we discover that a child under 16 has provided us with personal information, we will delete such information from our systems.

What personal data do we process?

We may obtain information about you in a variety of ways, including when you call, email or otherwise communicate with us (including through social media), or when you participate in events or other promotions. We also collect information given directly by you, by third parties (e.g., data providers, social networking account user ID), and automatically as you use our Apps. The personal data relating to you that we process may include the information set out below.

The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the "GDPR"). Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction.

A key component of our Apps is to assist our users in identifying telephone calls including potentially unwanted telephone calls, as well as automatically forwarding incoming calls we identify as a potentially “unknown identity/reputation” that are either missed or rejected by the user to voice messaging system that would appear on the App for retrieval by the user, in the event the caller leaves a voice message. To do so, we may collect call and text log information automatically from our users’ devices.

In addition, if you sign up to use the App, we may also process the following personal data relating to you:

If you contact us, we will collect whatever information you choose to provide in your correspondence with us often this includes your phone number, email address or other contact details.

We may combine this information with other information that we have collected about you, including, where applicable, your username, name, and other personal information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” for more information.

User Generated Content

We also invite you to contribute information in and on our Apps, including your comments in spam reports, spam category, name corrections and any other information that you would like to be available on our Apps. You also may have the option to send a picture or your location through our Apps to someone you call. These pictures will not be available to all users, only to the receiver of the sent picture. We will not text or call any of your contacts without your explicit consent. If you contribute information to our Apps, your posting may become public and we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. In general, if you choose to disclose information about other people to us, you confirm that you have the authority to use and share such information.

What do we do with your personal data?

We may process our users’ personal data as necessary to perform our contract with you, for our or third parties’ legitimate interests, especially to provide our Apps to you and other users, to assist our users in identifying potentially unwanted telephone calls, including the following:

Who do we disclose your personal data to?

What are the legal grounds for our processing of your personal data?

The legal bases on which we process your personal data is described below:

More specifically, and in some cases in addition to the purposes described above, we may use the information we collect for a variety of other purposes, such as the following:

Performing Our Services

Internal Research

Auditing Interactions with Our Users

Security

Debugging/Repair

Quality and Safety Maintenance and Verification

Protecting our rights and property

We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose, and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

Where do we process personal data?

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our partners. Your information for example could be transferred to the USA, Canada, Brazil, Singapore and Australia.

Where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards and that it is treated securely and in accordance with this Policy, such as relying on a recognized legal adequacy mechanism which may include entering into EC approved standard contractual clauses relevant to transfers of personal information.

How long do we process personal data for?

We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose. We may retain some of your information even after you uninstall or disable an App or close your account, except if you instructed us otherwise.

In particular, we may for an indefinite period process your call logs and spam reports which you granted us access to before uninstalling or disabling an App or closing your account. We do this strictly for statistical purposes, in order to enable us improving our algorithms and our services. We will not use these data for any other purposes, and the processing will have no effect on you or any other natural person. The data will not be shared with any third parties either, and we take appropriate measures to ensure that your data is safe with us.

What are your rights?

You have the following rights in relation to personal data relating to you that we process:

How can you disable the beta call forwarding feature in the app?

You can stop all information collection by the app by disabling call forwarding and deactivating your account by following the instructions on the app’s Protect screen and then uninstalling the app using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you reinstall the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

How can you exercise your rights?

You may exercise your above rights, including your right to withdraw your consent and access to your personal data, by:

- contacting us at Hiya Customer Service

- writing to us at any of the addresses specified on the top of this document.

You may also modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the App for a period of time.

Please note that we may be required to ask you for further information so we may confirm your identity before we provide the information requested.

Security

We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer/phone, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and similar technologies, including mobile application identifiers, to track information about your use of our Apps, help us recognize you across different Apps, improve your experience, increase security, measure use and effectiveness of our Apps, and serve advertising. We may combine this information with other personal information we collect from you, and our third-party service providers may do so on our behalf.

You may leave an App by linking to one of our Hiya Web pages (such as hiya.com and mrnumber.com), which also use cookies. Similarly, logging in through a social network subjects you to their respective cookie policy. You can control cookies through your browser settings and other tools.

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking. Specifically, you may turn off location tracking by changing the settings on your mobile device, although some features of the Apps may not be available if you do. By using or visiting our Apps, you consent to the placement of cookies and beacons in your browser and HTML based emails in accordance with this Policy, which incorporates by reference our Privacy Policy.

Frequency of Communications

In case you have given your consent to this, we may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 30 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

Changes to this policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post changes to this Policy on our Apps. If we make any changes to this Policy that materially affect our practices with regard to the personal information, we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Apps and their corresponding Web sites, sending a push notification, or displaying on any of the Web sites associated with our Apps.